This analysis describes what 23andMe's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The clause conditions access to the research program on explicit opt-in consent, meaning genetic data sharing with external research partners occurs only upon the user's voluntary enrollment rather than by default. This creates a distinct data usage pathway separate from 23andMe's primary service operations.
The updated privacy statement no longer explicitly directs users to a separate Medical Record Privacy Notice for telehealth services or explains that medical information collected through telehealth is governed by different privacy rules. Previously, the policy stated that users choosing telehealth services coordinated through 23andMe would find healthcare privacy protections described in a separate notice. That reference is now absent from the main privacy statement. Users seeking privacy information specific to telehealth services will need to determine independently whether a separate notice exists or contact 23andMe directly using the provided contact information.
View change record →The updated privacy statement no longer explicitly discloses a separate Medical Record Privacy Notice that previously described how medical information is used, disclosed, and maintained for telehealth services. Users who receive telehealth services coordinated through 23andMe may now lack clear notice of which privacy framework governs their medical records, since the reference to that parallel notice has been removed. The organizational scope change from '23andMe Research Institute' to '23andMe' narrows the explicitly named entities responsible for the policy, though operational impact depends on how these entities actually function.
View change record →Users who elect to participate in 23andMe Research authorize 23andMe to disclose their genetic information and self-reported health data to third-party research collaborators for research applications. Users who do not participate are not subject to these research-related data sharing practices.
How other platforms handle this
Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.
We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"You can choose to participate in 23andMe Research. 23andMe Research may include collaborations with third parties, such as pharmaceutical companies, and may involve your Genetic Information and/or Self-Reported Information. If you choose to participate in Research, your Genetic Information and/or Self-Reported Information may be used for research purposes, including being shared with third-party research partners, such as pharmaceutical or biotech companies.— Excerpt from 23andMe's 23andMe Privacy Statement
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
Your genetic data may be transferred to a new owner as a business asset. Here is what the Terms of Service actually say and what you can do right now.
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The clause conditions access to the research program on explicit opt-in consent, meaning genetic data sharing with external research partners occurs only upon the user's voluntary enrollment rather than by default. This creates a distinct data usage pathway separate from 23andMe's primary service operations.
Users who elect to participate in 23andMe Research authorize 23andMe to disclose their genetic information and self-reported health data to third-party research collaborators for research applications. Users who do not participate are not subject to these research-related data sharing practices.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by 23andMe.